In a crucial ruling in Pennsylvania, a federal court decreed that undated mail-in ballots must be counted. This decision, which was released on Monday, could substantially influence upcoming state elections. It also adds another layer to the prevalent legal conflicts over mail-in voting in Pennsylvania, a hot-button issue since the implementation of Act 77, a critical bill reforming voting in the state.
The court’s ruling came about during NAACP v. Schmidt. This case involves multiple individual voters and voting rights groups challenging the disqualification of mail-in ballots lacking a handwritten date on their return envelopes. The plaintiffs argued that this exclusion was a “meaningless technicality.”
The plaintiffs brought forth two key arguments in this case: that the law infringed upon the Materiality Provision of the Civil Rights Act and that it stood in violation of the Equal Protection clause under the US Constitution’s Fourteenth Amendment.
The Materiality Provision of the Civil Rights Act claim revolved around the plaintiffs’ contention that requiring a handwritten date next to the voter’s signature on mail ballots clashed with the Materiality Provision. This provision safeguards voters, stating that their ballots cannot be rejected due to minor errors or omissions, which are irrelevant to verifying their eligibility to vote. The plaintiffs argued that a missing or wrongly written date, which did not factor into establishing voting eligibility, should not render a ballot void. The court concurred with the plaintiffs, concluding that excluding votes due to missing or inaccurate dates on envelopes was a breach of the Materiality Provision.
In terms of the Equal Protection claim, the plaintiffs contended that Pennsylvania’s enforcement of the date requirement on mail-in ballot envelopes was applied inconsistently, thereby affecting domestic voters differently from overseas and military ones. Notably, they argued that any error in completing the ballot for overseas and military voters would not invalidate their ballots as long as the error did not impede determining their eligibility to vote.
However, the court declined to further pursue this claim. Adhering to the principle of judicial restraint, the court avoided ruling on broader constitutional issues when the case could be resolved on narrower grounds – in this case, the Materiality Provision. By deciding on the basis of the plaintiffs’ first claim, there was no need to venture into the constitutional issue of equal protection.
More about this case can be found here.